Section 23 is the section on solicitor-client privilege. It's a discretionary exemption. I think some of our most important work has to do with what factors are to be considered when we use discretion and how we review those cases. Often the discretion is well applied, but we have factors that are encouraging access versus other institutions that prefer more privacy or secrecy. On solicitor-client privilege, I can tell you that the case law is not helping us in giving access. The cases that deal with section 23 are unanimous: It's a privilege and it has to be protected.
What we're trying to do is to find lines with the current minister and his staff between what they consider pure solicitor-client privilege versus training manuals versus policies. Sometimes we have legal counsels involved in policy drafting, but these aren't legal opinions. We have a lot of examples. Definitely, these types of examples are the cases I want to use in the future to provide guidance on where my office is positioning itself with respect to those sections.